On a dose escalation study, the Data Manager notices one site has a much higher number of queries than other sites and most are older than 30 days. The Data Safety Monitoring Board will meet in three weeks. What should the Data Manager providing CRO oversight do?
The correct action is to consult the CRO's Lead Data Manager and CRO's Project Leader (Option C) to ensure the issue is addressed through the appropriate oversight and escalation process.
According to the GCDMP (Chapter: Project Management and Communication), when a sponsor Data Manager identifies significant data management issues under CRO oversight --- such as aging queries or site performance disparities --- communication must follow the established governance and escalation pathway defined in the Scope of Work (SOW) and Data Management Plan (DMP).
Directly contacting the site (Option B) bypasses the CRO's chain of command and violates communication protocols. Notifying only the Clinical Leader (Option A) is insufficient, and ignoring the issue (Option D) jeopardizes the Data Safety Monitoring Board (DSMB) review timeline.
Therefore, Option C ensures a documented, collaborative approach to problem resolution within the contractual oversight structure.
Reference (CCDM-Verified Sources):
SCDM Good Clinical Data Management Practices (GCDMP), Chapter: Project Management and Communication, Section 7.1 -- Oversight of CRO Data Management Activities
ICH E6 (R2) GCP, Section 5.2 -- Contract Research Organization Responsibilities
FDA Guidance for Industry: Oversight of Clinical Investigations -- Sponsor and CRO Roles and Communication Pathways
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